R (Prudential Plc) v Special Commissioner of Income Tax

JurisdictionEngland & Wales
JudgeLord Justice Aikens,Lord Justice Lloyd,Lord Justice Stanley Burnton,Lord Justice Mummery
Judgment Date14 December 2010
Neutral Citation[2010] EWCA Civ 1094,[2010] EWCA Civ 355
Docket NumberCase No: B2/2009/1240,Case No: C1 2009/2544
CourtCourt of Appeal (Civil Division)
Date14 December 2010
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6 cases
  • G v G
    • United Kingdom
    • Family Division
    • 24 April 2015
    ...manner ….'. 74 A modern restatement of the law can be collected from the decision of the Court of Appeal in R (Prudential PLC) v Special Commissioners of Income Tax [2011] QB 669 where Lloyd LJ (with whom Mummery and Stanley Burnton LJJ agreed) reaffirmed the principle that a conversation b......
  • Stewart Ford v Financial Services Authority—and Peter Johnson and Mark Owen and Another
    • United Kingdom
    • Queen's Bench Division (Administrative Court)
    • 18 April 2012
    ...relied. The difficulty in establishing LPP over that material was clear. The decision of the Court of Appeal in R (Prudential) v. Income Tax Special Commissioner [2011] 2 WLR 50 was handed down on 13 October 2010. The Court dismissed the appeal from the decision of Charles J in the Administ......
  • R (Prudential Plc) v Special Commissioner of Income Tax
    • United Kingdom
    • Supreme Court
    • 23 January 2013
    ...UKSC 1 THE SUPREME COURT Hilary Term On appeal from: [2010] EWCA Civ 1094 Lord Neuberger, President Lord Hope, Deputy President Lord Walker Lord Mance Lord Clarke Lord Sumption Lord Reed R (on the Application of Prudential Plc and another) (Appellants) and Special Commissioner of Income Ta......
  • UTB LLC v Sheffield United Ltd
    • United Kingdom
    • Chancery Division
    • 9 April 2019
    ...that is also privileged, nonetheless advice given by an unqualified lawyer does not attract privilege (see Prudential v. Pandolfo [2010] EWCA Civ 1094 (“ Pandolfo CA”) per Lloyd LJ at paras 73, 75 and 82, and Prudential PLC and Prudential (Gibraltar) Ltd v. Special Commissioner of Income T......
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7 firm's commentaries
  • Privilege update - two new decisions from the UK
    • New Zealand
    • Mondaq New Zealand
    • 1 November 2010
    ...such as a settlement agreement, and R (on the application of Prudential PLC and Anor) v Special Commissioner of Income Tax and Ors [2010] EWCA Civ 1094 (13 October 2010) in which the English Court of Appeal declined to extend legal professional privilege to chartered accountants giving lega......
  • UK Supreme Court Declines To Extend Scope Of Legal Advice Privilege
    • United Kingdom
    • Mondaq United Kingdom
    • 29 January 2013
    ...issue. Footnotes 1 R (on the application of Prudential PLC & Anor) v Special Commissioner of Income Tax & Anor [2013] UKSC 1 2 [2010] EWCA Civ 1094 Visit us at Mayer Brown is a global legal services provider comprising legal practices that are separate entities (the "Mayer Brown Pra......
  • Court Of Appeal Rejects Appeal For Extension Of Legal Privilege To Accountants
    • United Kingdom
    • Mondaq United Kingdom
    • 21 October 2010
    ...hearing of issues which raise matters of public policy. Footnotes 1 Prudential Plc v Special Commissioners of Income Tax and another [2010] EWCA Civ 1094 2 Paragraph 73 [2009] EWHC 2494 The content of this article is intended to provide a general guide to the subject matter. Specialist advi......
  • Court of Appeal Refuses to Extend LPP to Accountants
    • United Kingdom
    • Mondaq United Kingdom
    • 12 November 2010
    ...2 Prudential PLC and Prudential (Gibraltar) Limited v Special Commissioner of Income Tax and Philip Pandolfo (HM Inspector of Taxes) [2010] EWCA Civ 1094 The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your s......
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3 books & journal articles
  • Indexes
    • United Kingdom
    • International Journal of Evidence & Proof, The No. 18-4, October 2014
    • 1 October 2014
    .... . . . . . . . . . . . . . . . . . . . . . . . . . . . . .66R (on the application of Prudential plc) v SpecialCommissioner of Income Tax [2011] QB 669,[2009]EWHC 2494 (Admin). . . . . . . . . . . . . . 66R (on the application of Prudential plc) v SpecialCommissioner of Income Tax [2013] UK......
  • An Unsatisfactory Stalemate: R (on the Application of Prudential plc) v Special Commissioner of Income Tax
    • United Kingdom
    • International Journal of Evidence & Proof, The No. 18-1, January 2014
    • 1 January 2014
    ...replaced by the Finance Act 2008, s. 113 andSched. 36. 3 R (on the application of Prudential plc) v Special Commissioner of Income Tax [2011] QB 669, [2009] EWHC2494 (Admin) at [8] and [2010] EWCA Civ 1094 at [2]. 4 [2013] UKSC 1, [2013] 2 WLR 325 at [122]. 5 Ibid. at [137]. 6 Ibid. at [148......
  • Case Commentaries
    • United Kingdom
    • International Journal of Evidence & Proof, The No. 15-1, January 2011
    • 1 January 2011
    ...privilege for accountants—United KingdomThe applicant in R (on the application of Prudential Plc) vSpecial Commissioner of IncomeTax [2010] EWCA Civ 1094 applied for a judicial review to quash notices issuedunder the Taxes Management Act 1970, s. 20 (now Finance Act 2008, Sched. 36) toprodu......

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